ML20064M593
| ML20064M593 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/27/1982 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-577, NUDOCS 8209080030 | |
| Download: ML20064M593 (5) | |
Text
-.
g
-O UNION ELECTRIC COMPANY 1908 GMATIOT STREET ST. Louis. Missount uu. aoo....
a"^'i,**,""yu August 27, 1982
,,, g, ;,,,,,;*;,,,,,
o "a" Mr. Harold R. Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ULNRC-577 Washington, D.C. 20555
Dear Mr. Denton:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 FINAL SAFETY ANALYSIS REPORT REVISED COMMITMENT FOR AUDIT OF THE CALLAWAY RADIATION PROTECTION PROGRAM
Reference:
Union Electric Letter to the NRC (ULNRC-521) dated October 1, 1981, signed by D.
F.
Schnell Union Electric Letter to the NRC (ULNRC-531) dated December 10, 1981, signed by D.
F. Schnell i
This letter is being sent to inform you of a change in the designated group responsible for auditing the Callaway Radiation Protection Program.
To provide continuity in the Plant's audit
- programs, the audit activities of the Radiation Protection Program have been placed under the jurisdiction of the Quality Assurance Department instead of Nuclear Engineering.
The attachment gives the revised responF1 from the original commitment as set forth in the referenced documents.
This revised response is hereby incorporated into the Callaway Application and will be incorporated into the next revision of the Callaway FSAR Site Addendum.
Vei;y truly yours,
/
ut D f'd D.
. Sc ell DJW/lw
()
Attachmenti t)Y h209080030820027 DR ADOCK 05000 A
Attachment Item 260. 71C Section 17.1.2.2 of the standard format (Regulatory Guide 1. 70) requires the identification of safety-related structures, systems, and components controlled by the OA program.
.Y'ou are requested to supplement and clarify Table 3. 2-1 of the Callaway FSAR in accordance with the following:
a.
The following items do not appear on FSAR Table 3.2-1.
Add the appropriate itebs to the' table and provide a commitment that the remaining items are subject the pertinent requirements of the FSAR operational quality assurance. program or justify not doing so.
a.8 Radiation monitoring (fixed and portable)'
Callaway Position:
It is Union Electric's position that items 8-16 of 260. 71c(a) should not be include'd in Table 3. 2-1, or be be subject to the requirements of the operational quality assurance program.
Union Electric does feel that NUREG 0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees" Draft Report March 1981, which is presently in draft form and out for comments, provides the necessary guidance in formulating the Callaway Radiation Protection Plan.
The Callaway Radiation Protection Manual (CRPM) and Radiation Protection (RP) procedures together will constitute the Callaway Radiation Protection Plan (CRPP). outlines the proposed CRPM.
The outline lists the major areas to be addressed in the
, manual.
It is intended that the CRPM will be a concise statement of the Callaway Radiation Protection Plan that can be understood by all plant personnel.
The manual will be written in general-and brief terms with the specifics of the~ plan to be addressed in the implementing RP procedures.
The Callaway Radiation Protection Plan will be developed in accordance with applicable regulatory requirements,
~
regulatory guides, industry standards, and acco'pted industry practices, and will incorporate sufficient managerial and administrative control to ensure that a high level of radiation protection is provided.
outlines the implenenting procedures.
O J
_2_
These procedures have been broken down into areas as recommended by the NUREG.
It is intended that administrative controls will be implemented via incorporation into administrative and programmatic level procedures which will receive Onsite Rebiew Committee (Plant Review Group) review and approval.
To verify that radiation protection functions are being performed as required and that a high level of radiological safety is maintained, periodic review and aurit of the radiation protection program will be performed by the Quality Assurance Department.
Periodic is to be interpreted as annual; however, when warranted by identified program deficiencies a more frequent review schedule of the deficient area may be implemented.
The specifed audit frequency is based on established industry auditing practice and the assumption that an audit of annual frequency in combination with regulatory, ANI and INPO inspections will provide adequate review and evaluation of program performance. The performance of audit and review of the areas identified in iter; 8-16 to assure program effectiveness is consistent with the position of NUREG 0761.
Additional quality assurance for items 8-16 of 260.71c(a) are built into RP procedures utilizing quality assurance provisions from regulatory guides.
An example is the respiratory protection program.
Quality assurance for procurement of respiratory equipment is maintained by the purchasing of only NIOSH certified equipment.
In complying with Reg. Guide 8.15, additional quality assurance is established in the respiratory protection program.
6 m
STATE OF MISSOURI )
)
Robert J.
Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
W-C By m
Robert J. W6hukai General.Esviager-Engineering Nuclear SUBSCRIBED and sworn to before me this 27th day of August, 1982
&mb 9
MARGARET S. HEIDA NOTARY PUBUC-STATE OF MISSOURI ST. LOUIS COUNTY My COMMISSION EXPIRES JANUARY 2, IN6 I
i i
cc:
Glenn L.
Koester Vice President Operations Kansas Gas & Electric P. O.
Box 208 Wichita, Ka nsa s 67201 John E.
Arthur Chief Engineer Rochester Gas & Electric Company 89 Ea st Avenue Rochester, New York 14649 A.
V.
Dienhart Vice President Plant Engineering and Construction Northern States Power 414 Nicollet Mall Minneapolis, Minnesota 55401 Donald T.
Mc Phee Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnof f, Esq.
Shaw, Pi ttma n, Potts & Trowbridge 1800 M. Street, N.W.
Washington, D.C.
20036 Nicholas A.
Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S.
Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077